Defense Infrastructure: Additional Actions Could Enhance DOD's Efforts to Identify, Evaluate, and Preserve Historic Properties
Fast Facts
Federal agencies must evaluate the historic significance of their properties and consider historic preservation when maintaining their properties.
We reviewed DOD’s practices on its military installations. At most of the installations we visited, we found that:
In cases where homes had been transferred to private developers, developers said they did not try to identify historic significance
People working in preservation said they believed maintenance personnel did not always know what work was allowed on historic buildings
We made 7 recommendations, including that DOD verify that military homes in private hands are being evaluated.
This property’s windows were renovated with modern materials that reduced costs while maintaining historic character
Photo of a historic building
Highlights
What GAO Found
The Department of Defense (DOD) reported that it has identified and evaluated about 60,000 of its approximately 375,000 properties on installations as historic as of October 2017. DOD's practice is to identify and evaluate property for historic significance as installations have an identified need for or a project planned for the property, according to DOD officials. However, GAO identified opportunities for DOD to enhance its efforts in several areas.
- DOD lacks complete and consistent data on historic properties. Specifically, GAO identified data gaps and discrepancies between the data reported at the installation and department levels for fiscal year 2017. For example, for one installation, GAO found that 150 more historic properties were listed in its installation data than were listed in department-level data for that installation. In November 2018, GAO reported on issues concerning DOD's data and made recommendations to improve the data quality. DOD concurred and reported actions it plans to take to improve data quality. Doing so would help DOD to ensure it has complete information on properties of historic significance and prevent further data discrepancies.
- DOD has limited visibility of privatized homes that could be historic. When the military departments transferred military homes to private developers, DOD officials said they also transferred the responsibility to identify and evaluate homes for historic significance to the private developers. However, the military departments do not verify that private developers are doing so. Private developers at seven of the nine installations with privatized housing that GAO visited said they do not identify or evaluate homes for historic significance. Taking steps to verify that private developers carry out this responsibility could help DOD ensure that renovations or repairs are not made to privatized properties that could compromise their historic nature.
Additionally, DOD does not routinely assess the condition of its historic properties and a lack of guidance on training could hamper maintenance and preservation efforts. First, inventories of historic properties, including physical inspections, required every 3 years, are not being conducted at six of the 10 installations GAO visited. Officials at these six installations said that the inventory was not conducted because they were unaware of or misunderstood the requirement. Second, while each installation GAO visited had an established process for approving maintenance work orders, DOD officials reported problems with the maintenance of historic properties at these installations, ranging from maintenance personnel not addressing issues, to maintenance being conducted improperly. At nine of the 10 installations GAO visited, individuals who work in historic buildings said that they believed maintenance personnel did not know what maintenance could or could not be done to the historic buildings, and installation officials expressed concerns about a lack of training related to historic preservation. By clarifying the requirement to conduct a physical inventory and developing guidance on training, DOD would be better positioned to preserve the historic properties under its purview.
Why GAO Did This Study
The National Historic Preservation Act of 1966 requires each federal agency to establish a preservation program that ensures properties are identified and evaluated for historic significance, as well as managed and maintained in a way that considers their preservation.
Senate Report 115-130 accompanying a bill for the Military Construction, Veterans Affairs, and Related Agencies Appropriations Act for fiscal year 2018, included a provision that GAO assess DOD's management of historic properties in use on U.S. installations. This report examines the extent to which DOD (1) identifies and evaluates properties for historic significance, including those that have been privatized, and (2) assesses the condition of its historic properties and has guidance on the training of installation personnel maintaining and those working in historic properties. GAO reviewed DOD fiscal year 2017 real property data and policies and procedures; visited a non-generalizable sample of 10 installations, selecting them based factors such as military service representation and concentration of historic properties; and interviewed DOD officials, privatized housing developers, and installation personnel.
Recommendations
GAO is making seven recommendations, including that DOD take steps to verify that privatized military homes are identified and evaluated for historic significance; clarify the inventory requirement for historic properties; and develop guidance related to historic preservation training. DOD concurred with the recommendations.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Department of Defense | The Secretary of the Navy should take steps to ensure that Navy and Marine Corps' installation personnel verify that private developers are identifying and evaluating privatized properties for historic significance, as appropriate. (Recommendation 1) |
Closed – Implemented
The Department of Defense (DOD) concurred with GAO's June 2019 recommendation and provided GAO with a corrective action plan to ensure that privatized homes are evaluated for historic significance. Department of the Navy officials also acknowledged their oversight responsibilities related to privatized homes and told us that they would work to ensure privatized homes are evaluated for historic significance by reviewing and clarifying all applicable privatized housing agreements, programmatic agreements, and historic property inventories. In June 2021, the Navy provided information showing how it had clarified requirements with privatized housing partners, as needed; provided training during 2020 for Navy cultural resource managers; and provided appropriate language for inclusion in future privatized housing agreements regarding identification and evaluation of privatized properties for historic significance. The Navy plans to incorporate this guidance into future Integrated Cultural Resources Management Plans and verify that updated management plans contain specific information on National Historic Preservation Act compliance responsibilities for privatized housing assets. The actions taken by the Navy meet the intent of our recommendation.
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| Department of Defense | The Secretary of the Army should take steps to ensure that Army installation personnel verify that private developers are identifying and evaluating privatized properties for historic significance, as appropriate. (Recommendation 2) |
Open
The Department of Defense (DOD) concurred with GAO's June 2019 recommendation and provided GAO with a corrective action plan to ensure that privatized homes are evaluated for historic significance. In July 2019, the Army issued a Strategic Agenda for Army National Historic Preservation Act (NHPA) Improvement. The Army also stated that it had concluded that, based on its review of existing compliance agreements, the Army believes that identifying and evaluating privatized properties for historic significance is the Army installation's responsibility, not the private developer. The Army noted that its Army Federal Preservation Officer addresses all historic properties as defined in the National NHPA and will engage Army and Residential Communities Initiative (RCI) historic housing, including pursuing a programmatic Army-wide NHPA compliance solution with the ACHP to achieve efficiencies in historic housing NHPA compliance. The Army's Strategic Agenda also stated that, in order to ensure effective NHPA compliance, Commanders and their staffs must make certain that they have appropriate training and awareness of NHPA requirements, authorities, and other key aspects of the NHPA. However, as of August 2021, the Army had not yet fully implemented these efforts. We will continue to monitor DOD actions in this area and determine whether those efforts, once complete, meet the intent of our recommendation.
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| Department of Defense | The Secretary of the Air Force should take steps to ensure that Air Force installation personnel verify that private developers are identifying and evaluating privatized properties for historic significance, as appropriate. (Recommendation 3) |
Open
The Department of Defense (DOD) concurred with GAO's June 2019 recommendation. In addition, in 2022, the Air Force told us that the Department of the Air Force (DAF) agreed with GAO that NHPA Section 110 requires Federal agencies to screen property owned or controlled by the agency for National Registry eligibility. However, the Air Force also stated that because privatized housing on DAF installations is neither owned nor controlled by the Air Force and because NHPA Section 110 applies only to Federal properties under the ownership of control of the Agency, neither the project owners nor the DAF are required to screen housing owned by the project owners for National Register eligibility as those properties approach 50 years of age. Further, the Air Force stated that, if project owners transferred ownership of these properties to the DAF at expiration of the lease, DAF would evaluate the properties at that time. However, as we note in our report, DOD guidance states that because privatization creates a long-term governmental interest in privatized housing, it is essential that the military departments attentively monitor these privatization projects. Moreover, taking steps to ensure that installation personnel verify that private developers are identifying and evaluating privatized properties for historic significance, as appropriate, could help to ensure that private developers do not make renovations or repairs to properties that could compromise their historic nature. We continue to stand by our recommendation and will continue to monitor any efforts by the Air Force to implement it.
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| Department of Defense | The Secretary of the Navy should clarify the requirement for Navy and Marine Corps' installation personnel to conduct a physical inventory of historic properties every 3 years, including an assessment of each property's condition to ensure that facilities that have been identified and evaluated as historic are inventoried. (Recommendation 4) |
Closed – Implemented
The Department of Defense (DOD) concurred with GAO's June 2019 recommendation. In 2021, the Navy provided information confirming that the requirement to conduct an inventory of historic properties every 3 years is included in the Naval Facilities Engineering Command Real Property Inventory Procedures Manual (P-78), and that this requirement would be discussed at integrated natural resources management plan (INRMP) reviews, as applicable. In addition, in 2022, the Navy provided us with a Commander, Navy Installations Commend (CNIC) instruction, which explicitly states that installation commanding officers will conduct a physical inventory for all heritage assets at least once every 3 years and that they will also verify that all real property information is recorded accurately in the Navy Facilities Asset Data Store (iNFADS). The instruction further state that installation commanding officers will report to the CNIC the physical inventory status of all heritage assets annually, as of 30 September at the end of each fiscal year. The actions taken by the Navy meet the intent of our recommendation.
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| Department of Defense | The Secretary of the Army should clarify the requirement for Army installation personnel to conduct a physical inventory of historic properties every 3 years, including an assessment of each property's condition to ensure that facilities that have been identified and evaluated as historic are inventoried. (Recommendation 5) |
Closed – Implemented
The Department of Defense (DOD) concurred with GAO's June 2019 recommendation and provided GAO with a corrective action plan to ensure that Army installation personnel conduct a physical inventory of historic properties every 3 years. In our June 2019 report, we found that the military departments were not regularly completing inventories of historic properties because officials were unaware of or misunderstood the requirement to do so. In June 2019, the Army updated its Real Property Management handbook to include a description of the inventory requirement and the procedures for entering information gathered during the course of the inventory into real property management systems. The updated handbook also required each land-holding command to establish procedures whereby each garrison certifies the physical inventory conducted at their installation annually. The Army also issued a memorandum in June 2019 describing the inventory requirement and establishing deadlines for land-holding commands to report on the status of inventory efforts each year. The actions taken by the Army meet the intent of our recommendation.
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| Department of Defense | The Secretary of the Air Force should clarify the requirement for Air Force installation personnel to conduct a physical inventory of historic properties every 3 years, including an assessment of each property's condition to ensure that facilities that have been identified and evaluated as historic are inventoried. (Recommendation 6) |
Closed – Implemented
The Department of Defense concurred with GAO's 2019 recommendation. In 2021, the Air Force Civil Engineer Center (AFCEC) issued a Guidance Memorandum for Base Civil Engineers stating the importance of identifying facilities that are due for review and working with base Cultural Resources Managers (CRM). The Memorandum stated that the Real Property Accountable Officer (RPAO) is responsible for identifying buildings and structures that reach 45 years of age and reporting them to installation CRMs. It also stated that the RPAO must conduct physical inventories of buildings and structures that are already categorized as historic properties every 3 years, including documenting the facility condition and updating appropriate databases to ensure that all historic facilities are inventoried 100 percent, every 3 years. The Air Force found that, based on AFCEC's assessment, almost 90 percent of the nearly 7,500 facilities identified as historic across the Air Force portfolio were overdue for their 3 year inventory inspections, and that more than 1,000 buildings and structures that exceeded 50 years of age were overdue for evaluation. AFCEC provided Air Force installations guidance for corrective action to ensure the identification of these facilities by the RPAOs and ensure 100 percent compliance with the 3-year physical inventory requirement. In 2022, DOD provided us with information showing that all of the corrective actions in this area have been completed. Specifically, according to information from the Deputy Assistant Secretary of the Air Force (Environment, Safety and Infrastructure), Air Force installations are now 100 percent complete with notifying all base CRMs of any facilities meeting the 45-year threshold criteria requiring evaluation and 99 percent compliant with inventory inspections for all already-identified historic facilities (with delays for some inspections due solely to the remoteness and accessibility of some facility locations). Taken together, the actions implemented by the Air Force meet the intent of our recommendation.
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| Department of Defense | The Secretary of Defense should ensure that the Under Secretary of Defense for Acquisition and Sustainment, in collaboration with the military departments, develop and disseminate department-wide or service-wide guidance, on training related to historic preservation to installation personnel, including information on roles and responsibilities. (Recommendation 7) |
Closed – Implemented
DOD concurred with this June 2019 recommendation. In Spring 2022, DOD provided GAO with its memorandum to the military departments, the Defense Logistics Agency, and the Washington Headquarters Service on Historic Preservation Training, along with its guidebook on DOD Cultural Resources Training Overview. Regarding the training memorandum, DOD noted that regular cultural resources training for installation personnel and appropriate contract support ensures that compliance requirements are met in a timely and cost-efficient manner and that military service members and their families have suitable housing and work environments. DOD further noted that installation personnel who do not have proper training and awareness in cultural resources can result in DOD being unable to fully engage in meaningful consultation with stakeholders, including Tribes. DOD stated that having qualified and well-trained personnel not only enhances its compliance requirements, but also reinforces its stewardship mission and fosters relationships with stakeholders. Regarding the guidebook, DOD stated that the guidebook is intended to provide guidance to DOD components on cultural resources training needs and opportunities for their staffs. It also includes the existing training resources that DOD components have established on cultural resources, historic preservation, and Tribal communication and consultation, as well as training opportunities developed by the Office of the Secretary of Defense, other Federal agencies, and non-profits. The actions taken by DOD meet the intent of our recommendation.
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